Welsh Water s Statement of Risks, Strengths and Weaknesses 2016/2017

Transcription

1 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/07

2 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 Statement of Risks, Strengths and Weaknesses Who we are Welsh Water is the sixth largest of the ten regulated water and wastewater companies in England and Wales. Our primary responsibility is to deliver safe and reliable drinking water and sanitation to the. million people we serve across most of Wales, Herefordshire and parts of eeside. We provide an essential public service and, as custodians of the water industry in our area, we are responsible for protecting the environment and delivering a high quality and reliable service to our customers. Our vision Customers must be able to trust that the essential services we deliver are safe and of the highest standard. We know that we are relied upon to do the right thing on their behalf. This is why we put customers first. They are at the heart of everything we do. We will earn the trust of our customers every day be delivering high quality essential services that protect our customers health, our communities and the environment around us. Our values We re proud to put our customers first. We strive for excellence in all that we do. We re always open to new ideas and challenge ourselves to discover better ways of working. We are safe in everything that we do and never cut corners. eing honest, even when things are difficult, means our colleagues and customers can always trust us to do the right thing. y living by these values, every day, we will earn the trust of our customers. CONTENTS. ackground and Context. Our pproach. bout this ocument 4. Our Company Culture and Governance 5. Our ssessment of ata Quality Risks 5 6. Results of ssessing the Impact of ata Quality Risks 5 7. Results of ssessing the Probability of ata Quality Risks 6 8. Summary of ata Quality Risks 8 9. Next Steps 9 ppendix : Impact and Probability Risk Matrix - irection of Travel from 05/6 to 06/7 ppendix : Impact and Probability Risk Matrix 06/7 ppendix : efinition of Performance Measures

3 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7. CKGROUN N CONTEXT.. In the summer of 07 we will publish our nnual Performance Report for 06/7. This will be along the lines of Performance Reports we have published for many years. The report will enable stakeholders to assess how we have performed against those measures of success that are regarded by our customers as being the most important (the Performance Measures ). The targets for the Performance Measures were agreed with customers as part of an extensive customer engagement exercise carried out when we were preparing our business plans for the 05-0 period... It is important that we provide information to customers and stakeholders that is customer-led, accessible, clear, accurate, transparent and timely. Our ongoing objective therefore is to make available information that is easy to understand and navigate and which enables them to understand how we are performing. We also recognise that this helps build trust and confidence in the business... Last year Ofwat reviewed the performance of all water companies, using an assessment of historic performance against a number of criteria. Of the 9 companies, two were classified as selfassured (the highest category) and only one was placed in the prescribed category (the lowest category). Welsh Water, along with the other 5 companies, was placed in the targeted category (i.e. the middle category). In assigning us to this category, Ofwat concluded that we have demonstrated that we are able to deliver accurate and reliable information that gives stakeholders trust and confidence. We are awaiting the latest review from Ofwat..4. Ofwat also acknowledged that we are best placed to identify the risks, strengths and weaknesses associated with providing information of the quality they would expect to see. To allow us to develop a targeted assurance plan, we have therefore undertaken a reporting risk assessment for all relevant data that will be contained in the nnual Performance Report. This was an important exercise and was the basis of this Statement of Risks, Strengths and Weaknesses.. OUR PPROCH.. We welcome Ofwat s approach consistent, high-quality, timely and comprehensive information is vital to support good decision-making and improve service outcomes. The reliability and accuracy of data is a matter of great importance to us and this is an opportunity to build on what we have had in place for some time. We have retained many of the processes and initiatives which have served the business well such as quality assurance of data, due diligence, training and process mapping... We have an audit and assurance framework in place designed to allow the systematic monitoring and evaluation of the various aspects of our performance to ensure that standards of quality are being met. This involves having appropriate governance arrangements, close involvement by our oard in the assurance process, and the right level of independence in the process to provide third party review and challenge. This provides assurance to our oard, stakeholders and customers to give legitimacy and certainty of the level of performance and service that we are delivering... The information that we publish on our performance will be assured to maintain and build a high level of trust and confidence from our customers and stakeholders. dopting a risk based approach to assurance, and using internal and external review provides robust challenge and scrutiny of our performance..4. Our risk based assurance approach examines our end to end outcomes reporting process to identify the risks, strengths and weaknesses that may arise in providing the quality of information that customers and stakeholders trust. It also examines the probability of these risks materialising, and also the potential impact that they may have. This ensures that we focus on the areas which would have the highest impact, and allows us to take action to monitor and actively manage any risks.

4 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7.5. The approach we have followed is based on the methodology set out by Ofgem which was developed to provide guidance on best practice for conducting and reporting Risk ssessment and data assurance activities in order to ensure complete, accurate and timely data is submitted. Our approach has been independently reviewed and endorsed by KPMG who concluded that: We have a good understanding of Ofwat s requirements and our policy documents and risk mapping documents cover all the necessary bases; and Our ata ssurance Plan (based on the methodology set out by Ofgem) is appropriate. OUT THIS OCUMENT.. This Statement sets out our view of the strengths and weaknesses of our data assurance framework. irstly, it considers the features of our corporate culture and governance regime that supports the quality of reported data. Secondly, it reports on the results of our detailed risk assessment. 4 OUR COMPNY CULTURE N GOVERNNCE 4.. Our approach to data assurance leads us to consider risks associated with processes and identify specific controls that are in place to manage or mitigate them. However, it is important to remember that these controls do not operate within a vacuum and take place within an organisation with its own culture and governance which itself provides a level of reassurance for many risks. 4.. The culture of our Company is defined by the values we adopt and the knowledge, skills and attitudes of our employees. We have made it our vision to earn the trust of our customers every day. It is vitally important that we act responsibly as individuals and as an company at all times not only when we are required to do so by law, but also generally, in our working lives. 4.. We are committed to ensuring we give our employees the tools to do their job, which is why we invest in many internal development schemes. We take pride in being Investors In People accredited for the work that we do in making people the best that they can be We work in an environment where managers don t hide away in offices and there is an open door policy at all times, so if a colleague has a question, they will always be able to get an answer. This enables us to build closer working relationships, accessibility and an open flow of communication Our culture is a cornerstone of the data assurance process and is based on shared values and beliefs. It helps shape the way we conduct our everyday business and ensures we strive to do the right thing. ecause of its importance, company culture is sometimes described as a layer of control even preceding the first line of defence against inaccurate information. Maintaining a positive culture is important to us because: everyone is aware of the expectations regarding high quality information; other controls will focus on checking and correcting errors, but in a positive corporate culture, errors are less likely to arise because individuals create, record and transmit information completely and accurately as part of the way they work; other controls are laid over the top of the information-reporting process, but cultural controls are embedded within it; other controls might be occasional or periodic, but culture is ongoing and permanent; and everyone knows that they can be honest about data errors Corporate governance is the system of rules, practices and processes we put in place to run our business effectively, ensure we meet our legal and regulatory obligations and effectively manage our risks. Good governance is fundamental to all of our activities; it helps to build the trust of our customers and other stakeholders and aids effective decision making. 4.7 Culture is much more about people than it is about rules. We see our Code of Conduct as a baseline; a culture is created by what we do rather than what we say.

5 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/ In terms of data assurance, we consider that the following features of our culture and governance framework are strengths: Two of our six corporate Values are Trusted to do the right thing and Excellence in everything we do. These apply to the handling of information as much as any other process. We expect all our managers to be honest and trustworthy and act with integrity at all times. These behaviours are written into our Corporate ehaviours ramework. Our employees understand and appreciate the value attached to data quality and the processes used to generate the data. The Regulation epartment provides advice and guidance in the form of Information Packs and one-to-one training sessions. Our Corporate ehaviours ramework actively encourages colleagues to have the confidence to raise any concerns about inaccurate information or suggest improvements to existing processes that will improve data quality. The options available to colleagues wishing to raise any concerns are detailed in our whistle blowing procedure. Reviews of performance are conducted regularly throughout the Company from oard level to individuals. This includes those carried out by the oard, the Chief Operating Officer, the Quality and Environment Committee and the ŵr Cymru Executive Team. The Reporter carries out a formal review and certification of all Performance Measures and provides a detailed report commenting on compliance with procedures, relevant regulatory reporting requirements and highlights any issues with the reported figures. This includes checking the source of data, compilation of the data including the process of any extrapolation and assessing the adequacy of reported data. In addition, the Reporter will review and score all of our Methodology Statements which exist for all of our key measures.t head of the publication of the Performance Report, the internal usiness ssurance team carry out a high level audit and evaluation of the systems in place on the reporting framework within ŵr Cymru and review the effectiveness of the system of risk management, control and governance. programme of internal audits is approved and overseen by the udit Committee to assess the adequacy of control, governance and risk management processes. The results of these audits are reported to the udit Committee, which ensures that actions arising from internal audits are completed on a timely basis. Some of our key stakeholders also carry out audits and scrutiny of our data. or example, Natural Resources Wales carry out an annual audit on our operator self-monitoring (OSM) data for sewage treatment works covering sample scheduling, analysis, storage, reporting and use of data. They have carried out a first audit of our permitted flow monitoring data provision/use. Site inspections are also carried out at a number of our sewerage treatment works each year and data/data management is often assessed during these. CCWater also conduct regular assessments of our process for dealing with written complaints from customers. We have a well embedded risk management process that identifies, assesses and manages our risks. ll colleagues play a part in risk management. Individual teams within the business take responsibility for managing risks within their areas of responsibility. These are discussed every month at a meeting of the Executive team. The Executive team s update on strategic risks affecting the business is reviewed at every oard meeting. Robust financial control monitoring processes provide assurance that our key financial controls are operating effectively, and that we can trust the financial information produced by our accounting system. Our Internal Management System (IMS), which has accreditation to various ISO Standards, has been established to reinforce the management of risks associated with many areas of our business and compliance with obligations. udits of compliance with this system are conducted internally and by our third party certifiers (SI). 4

6 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 5 OUR SSESSMENT O T QULITY RISKS 5.. Risk is defined as an uncertain future outcome that, if it occurs, will have negative effects on the quality and reliability of nnual Performance Report submissions. Risk is specified by the combination of the probability of it occurring and a measure of the impact should it occur. Risk relates to the level of expectation that inaccurate or incomplete data will be submitted to our stakeholders in the future and the possible consequences. 5.. The overall Risk profile for each Performance Measure is determined by assessing both the probability of it containing an error and the impact this error would have across key drivers. Therefore, the Risk Matrix comprises two component metrics the Impact Metric and the Probability Metric. The Total Risk Rating is a combination of both metrics. 5.. The probability element of Risk is proxied by the Probability Metric and the impact element of Risk is proxied by the Impact Metric. The Impact and Probability Metrics are defined as follows: Impact Metric: a measure to represent the impact of an identified Risk materialising. It relates to the expected impact of inaccurate or incomplete data on stakeholders, our finances, our reputation and our coverage in the media. It is scored by assessing each performance data measure against the specified impact categories. Probability Metric: a measure to represent the probability of error occurrence. It is scored through the evaluation of the processes for data collection, reporting and the related control systems and processes. 6 RESULTS O SSESSING THE IMPCT O T QULITY RISKS 6.. The Impact Metric has four ratings, to 4, with 4 denoting the highest level of adverse impact and denoting the lowest level of adverse impact that would arise (in a realistic worst-case scenario) due to the use of inaccurate or incomplete data. 6.. To calculate the Impact Metric we use the three categories: a. inancial; b. Reputational (including Media coverage); and c. Stakeholders; and score on a scale of to To calculate an overall impact score for a Performance Measure, we take the highest score of all impact categories. We interpret the impact assessment as being the associated impact of inaccurate or incomplete data and not the impact associated with poor performance that the data might reveal. In doing so, we assume a realistic worst-case scenario Our assessment of the impact that inaccurate or incomplete data would have on our Performance Measures is detailed in Table overleaf. 5

7 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 Table. Impact Scores for all our Measures of Success Low Impact () Moderate Impact () High Impact () Very High Impact (4) G (Competence for Role) SC (Net promoter score) C (Responding to climate change) C (Carbon footprint) (t risk customer service) 4a (usiness customer satisfaction) 4b (usiness customer satisfaction) 5 (Earning the trust of customers) SC (ad debt) (Customer cceptability) (Reliability of supply) (bstraction of water for use) a (Preventing Pollution incidents - sewerage and water) b (Preventing Pollution incidents - sewerage and water cat) (Properties flooded in the year) E (ffordable bills) a (Safe rinking Water % of samples compliant) b (Safe rinking Water Mean Zonal Compliance (Treating waste water) (Service Incentive Mechanism) (Serviceability water/waste) a (sset resilience - Water) G (RIOR Incidents) E (Help for disadvantaged customers ) (Leakage) b (sset resilience - Waste) H (inancing Efficiency - Credit rating) SC (Complaints) 7 RESULTS O SSESSING THE PROILITY O T QULITY RISKS 7.. The Probability Metric has four ratings, from to 4, with 4 denoting the highest probability and denoting the lowest probability of inaccurate or incomplete data. There are seven categories that are scored for each Performance Measure in order to calculate its probability score. These are:. I. Complexity of data sources. I. Completeness of data set Inherent Probability. I. Extent of manual intervention 4. I4. Complexity and maturity of reporting rules 5. C. Control activities 6. C. Experience of personnel Control rameworks 7. C. Evidence of historical errors with this data 6

8 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 7.. I to I4 reflect the inherent (I) probability of error where no additional controls (on top of general system or process controls) are used to reduce Risk. C to C reflect the control (C) framework in place to reduce the probability of error. Combining these gives the overall probability of error, taking into account any controls that are in place. 7.. The overall probability score ranges from to 4 and all other factors being constant, high inherent Risk or a weak control environment should result in a higher Risk score, while low inherent Risk or strong control environment should result in a lower Risk score We might expect to see greater variation between Performance Measures in the Probability Metric Scoring than we would expect for Impact Metric Scores. This is because each Performance Measure will have different reporting systems, processes, and control environments for reporting data We consider that robust control frameworks are in place for all our Performance Measures. Within last year s (05/6) Risks, Strengths and Weaknesses Statement we included six Performance Measures as High Risk which was generally a combination of several factors including: the fact that in the main they were new Performance Measures introduced in pril 05 and the proper operation of internal controls had not yet been independently tested by our in house internal audit team or our external third party expert the Reporter; they were complex areas that require an element of judgement; and recent regulatory reporting issues within the water sector in general Each year, and for all Performance Measures, the Reporter undertakes the following: nalysis of management controls, governance, independent review and oversight, audit coverage, impact, inherent risk and controls for each measure; Review of the methodology used and the adequacy of methodology documentation; Checks that the methodology actually used conforms to Methodology Statements; Checks on the sources, adequacy and completeness of data used for the analysis; udits of the reported numbers to check that these are consistent with the base data and have been correctly compiled from it; Confirms the establishment of robust and transparent audit trails; and Makes recommendations aimed at improving assurance, if any are necessary In their 05/6 PR ssurance Report, the Reporter concluded that for all our Performance Measures, including the six specifically targeted, there is appropriate quality assurance with checks and controls identified and applied, including over the sources required to report your performance or each Performance Measure, the Reporter produced a Summary Sheet outlining the findings of the review and where appropriate enhancements to existing processes. These findings were used to update the Impact and Probability Risk Matrix produced for the 05/6 Risks, Strengths and Weaknesses exercise The result of our update exercise was that the risk profile for each of the six targeted Performance Measures reduced. In total, the risk profile for half of our Performance Measures reduced while the other half remained the same. ppendix shows the direction of travel of the risk profile for each individual Performance Measure. ppendix shows the final Impact and Probability Risk Matrix for 06/7. 7

9 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 8 SUMMRY O T QULITY RISKS Performance Reporting 8.. We will use the Impact and Probability Risk Matrix for 06/7 (ppendix ) as the focus to direct our assurance activities. When drawing up our assurance plans we generally prioritise the Performance Measures that fall within the red zone (High Risk) or amber zone (Medium High Risk). However, it can be seen from ppendix that no Performance Measures currently reside within either of these zones. 8.. Instead, we will focus on the Performance Measures within the yellow zone (Medium Low Risk). Our objective will be to highlight opportunities to improve our control framework further. We will achieve this by reviewing in-depth the respective Risk and Control ssessment Matrix. We adopt a rigorous and methodical approach to assessing the data quality risks for each Performance Measure. We identify the key processes used throughout the data reporting cycle, understand the inherent risks, and determine whether our existing controls are adequate and efficient in mitigating those risks. We refer to this as our Risk and Control ssessment Matrix. Our Regulation Team, with appropriate support from our Compliance Team and the Reporter, will work closely with colleagues within the business to examine whether we can introduce additional controls or strengthen existing ones to reduce the residual risk likelihood value. 8.. The Medium Low Risk Performance Measures we propose to target during 06/7 are: E a b G isadvantaged Customers Properties looded in the Year Serviceability Leakage sset Resilience Water sset Resilience Waste RIOR eveloper Services 8.4. The Water ct 04 introduced new obligations in relation to the services we offer to developers. We have also begun to voluntarily report our performance along with other water companies, so that customers can compare the standard of service they receive from us in context with the rest of Wales and England. Given these new requirements, and in the light of forthcoming statutory changes, this will be an area of focus for our future assurance plans. Price Control and Segmental inancial Reporting 8.5. The introduction of separate price controls for water, waste, household retail and non-household retail will place further customer (retailer) scrutiny on how we allocate our costs between wholesale and retail activities, augmenting the importance of cost allocation Our 05/6 nnual Performance Report contained greater details of our financial reporting with income and expenditure being reported against each price control and also against different accounting units. This is an area that we will focus assurance activities on, including external assurance conducted by an independent third party, to provide stakeholders with continued confidence in our reported figures. 8

10 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 usiness Retail Market Reform 8.7. The Water ct 04 introduces a new framework of retail competition for non-household customers. Our Licence Condition R Retail Market Opening, places a requirement on us to be ready for the opening of the business retail market to competition in pril 07. This is an area that we will focus assurance activities on to allow our business customers to have confidence in any performance data published. Website Publications 8.8. There are a number of key publications on our website for customers and stakeholders to use that explain not only our performance but also our main policies and practices. When considering the scope of our 06/7 data assurance process we believe it is important to include this wide range of publications and not purely focus on our nnual Performance Report and inancial Reports as our customers and stakeholders rely on the full range of information we provide not just what might be regarded as the core regulatory publications. This is an area will engage with our Customer Challenge Group to ensure they are content with the scope of documents included in the data assurance process and also to canvass views on how, relevant, understandable and easy to access the information is. 9 NEXT STEPS 9.. We will use the results of our Risks, Strengths and Weaknesses Statement to inform the ssurance Plan that we will develop in the coming months. s in previous years our ssurance Plan will include a variety of assurance measures including internal reviews by colleagues within ŵr Cymru, audits by the Company s Internal udit team and audits by third party organisations. Once we have considered stakeholders views on our risk assessment process we will publish our ssurance Plan in draft. We will invite stakeholders views on the draft plan. We will then publish our final ssurance Plan in March 07, having considered stakeholder feedback. 9

11 Impact Score Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 PPENIX. Impact and Probability Risk Matrix - irection of Travel from 05/6 to 06/7 Ref Performance Measure Risk a Safe rinking Water % of samples compliant b Safe rinking Water Mean Zonal Compliance Customer cceptability Reliability of supply bstraction of water for use Treating waste water a Preventing Pollution incidents Cat, & b Preventing Pollution incidents Cat only C Responding to climate change C Carbon footprint Service Incentive Mechanism t risk customer service Properties flooded in the year 4a Non Household customer satisfaction % 4b Non Household customer satisfaction score 5 Earning the trust of customers E ffordable bills E Help for disadvantaged customers sset Serviceability water/waste Leakage a sset resilience (Water) b sset resilience (Waste) G H&S RIOR Incidents G Competency for role H inancing Efficiency - Credit rating SC ad debt SC Net promoter score SC Complaints 4 E H SC SC SC a b G 4a a b C 4 E G a b 5 C G G C E C b a 0 4

12 Impact Score Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 PPENIX. Impact and Probability Risk Matrix 06/7 Ref Performance Measure Risk a Safe rinking Water % of samples compliant b Safe rinking Water Mean Zonal Compliance Customer cceptability Reliability of supply bstraction of water for use Treating waste water a Preventing Pollution incidents Cat, & b Preventing Pollution incidents Cat only C Responding to climate change C Carbon footprint Service Incentive Mechanism t risk customer service Properties flooded in the year 4a Non Household customer satisfaction % 4b Non Household customer satisfaction score 5 Earning the trust of customers E ffordable bills E Help for disadvantaged customers sset Serviceability water/waste Leakage a sset resilience (Water) b sset resilience (Waste) G H&S RIOR Incidents G Competency for role H inancing Efficiency - Credit rating SC ad debt SC Net promoter score SC Complaints 4 a E SC SC b H 5C G a b 4a G E C 4b C a b 5 4

13 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 PPENIX efinition of Performance Measures. Ref a b a b C C Performance measure Safety of rinking Water (% compliance) Safety of rinking Water (Mean zonal compliance) Customer acceptability Reliability of Supply bstraction of water for use Treating wastewater Preventing pollutions (cat,&) Preventing pollutions (cat only) Responding to climate change Carbon efinition Provide safe drinking water that meets the rinking Water Inspectorate s standards. The percentage of the sample tests that are compliant with the standards. We take over 50,000 samples tests per year at our water treatment works, service reservoirs and at customer taps. Mean Zonal Compliance (MZC) is published annually in the rinking Water Inspectorate (WI) report and is their primary measure used to compare overall water quality performance between water companies and regions of England & Wales. The MZC covers 9 different parameters, such as Iron, Lead and luminium, which are tested to establish the quality of water as received by customers. The number of contacts received from customers in the year regarding the appearance, taste or odour of drinking water. The average number of minutes that customers are without water within our supply area (includes both planned and unplanned interruptions). The percentage compliance with our abstraction licences, as issued by Regulators. or each of our wastewater treatment works there is a permit which regulates the quality of wastewater the company is allowed to discharge into rivers and coastal waters, which is regulated by the NRW. The measure is the % compliance against the discharge permits. Reduce the number of pollution incidents (caused by blockages or collapsed sewers). Pollution incidents are categorised as category, or incident and reported by the Natural Resources Wales. Category are the most severe and are major or serious impact on the environment, people or property. Category - significant impact or effect on the environment, people or property. Category - minor or minimal impact on the environment, people or property. s above but only category pollution incidents (minor or minimal impact on the environment, people or property). Reduce the amount of rainwater entering our sewers. The measure is the volume of surface water removed from the system, expressed as number of properties. To generate more renewable energy and therefore to offset our carbon emissions and the cost of imported energy. footprint SIM Service incentive mechanism (SIM) is a measure introduced by the Regulator Ofwat to monitor and report customer service information across all water & wastewater companies as a comparative measure. t Risk Customer Service Properties flooded in the year The number of customers who are on our register of at risk. They are deemed to be at risk because their service has repeatedly fallen short in one of the following five areas: discolouration of water, interruptions to supply, low pressure, and odour from wastewater assets and sewer flooding. The number of properties suffering internal sewer flooding per year.

14 Welsh Water s Statement of Risks, Strengths and Weaknesses 06/7 Ref Performance measure efinition 4a usiness Customer usiness customer satisfaction as measured by either satisfied or very satisfied in the six monthly survey undertaken. Satisfaction % satisfied 4b usiness Customer usiness customer satisfaction as measured by the average customer score out of a total of 5 then converted to a percentage. Satisfaction 5 Earning the Customer trust as measured in an annual survey. Trust of Customers E ffordable ills The company will continue to make bills more affordable by maintaining falling bills in real terms, beating inflation by at least % a year. E Help for isadvantaged customers Help more customers who genuinely struggle to pay their bills by providing assistance through social tariffs. sset Serviceability Maintain our assets. Serviceability includes a basket of sub-measures used to monitor the effectiveness of our asset management and the maintenance of our assets. Leakage Reduce our leakage levels. sset Resilience Health & Safety RIOR Competence for Role inancing Efficiency ad ebt Net Promoter Score Complaints Improve the resilience score of our most strategic assets. Improve the percentage of strategic assets that are resilient against a set of criteria. Strategic assets are those where failure would have a major impact on service to customers or on the environment. Keep colleagues safe by reducing the number of RIORs (Reporting of Injuries, iseases and angerous Occurrences Regulations) each year. Ensure our colleagues are trained to be fully competent in their roles. Maintain our grade credit rating or equivalent, so we continue to access low-cost long term finance. The measure to record the value of bad debt (unpaid customer bills). survey undertaken across a number of companies (not just water utilities) to establish how our customers rate Welsh Water service in comparison to other companies. The number of written customer complaints we receive.